CLAIBORNE PARISH SCHOOL BOARDLocal Government

Reference # and title: 2025-001 Untimely Completion of Time Certifications Federal program and specific federal award identification: AL Number Award Year FEDERAL GRANTER/ PASS THROUGH GRANTOR/PROGRAM NAME United States Department of Agriculture; passed through Louisiana Department of Education Child Nutrition Cluster: School Breakfast Program 10.553 National Lunch Program 10.555 2025 2025 Criteria or specific requirement: Federal regulations require that salaries and wages charged to federal programs be supported by time and effort documentation that accurately reflects the work performed and is completed in a timely manner, in accordance with 2 CFR §200.430. Condition found: In testing a sample of Child Nutrition payroll, it was noted for all eleven employees tested, the Child Nutrition Program did not complete required time certifications in a timely manner. Several certifications were completed after an extensive amount of time, resulting in noncompliance with federal documentation requirements. Context: This finding appears to be systemic. Possible asserted effect (cause effect): Cause: The School Board did not have an sufficient procedures or monitoring controls to ensure that time certifications for Child Nutrition Program employees are completed timely and in accordance with federal requirements. Effect: The School Board’s internal controls over allowable costs were weakened. Recommendations to prevent future occurrences: The School Board should implement written procedures to ensure all Child Nutrition Program employees complete time certifications timely and in accordance with federal requirements. Management should also establish a review and monitoring process to verify certifications are completed accurately and retained on file prior to charging payroll costs to the program. Origination date and prior year reference (if applicable): This finding originated fiscal year ended June 30, 2025. View of responsible official: The School Board agrees and will comply with the recommendations.

Reference # and title: 2024-001 Controls over Cash Management Federal program and specific federal award identification: CFDA Number Award Year FEDERAL GRANTER/ PASS THROUGH GRANTOR/PROGRAM NAME United States Department of Education; passed through Louisiana Department of Education Title IV – SSAE 84.424 2024 Title IV Set Aside – SSAE 84.42A 2022 Stronger Connections Grant Program 84.424F 2023 Criteria or specific requirement: Good internal controls require that all requests for reimbursement submitted to the Louisiana Department of Education (LDOE) are adequately reviewed and approved either before submission or after submission, but in a timely manner, to ensure amounts reported are complete and accurate. Condition found: In testing a sample of a requests for reimbursements across all SSAE grants, it was noted that for the Stronger Connections Grant, the request for reimbursement was not reviewed and approved in a timely manner, in which the review and approval did not occur until three months after submission. When testing a sample of claims for reimbursements for the Title IV grants, it was noted that the reimbursements were not reviewed and approved by the supervisor. It was further noted that these reports were not printed until the auditor had requested them and were signed off by someone other than the supervisor as required by the procedures of the School Board. Context: This finding appears to be systemic. Possible asserted effect (cause effect): Cause: The School Board did not have an adequate review and approval process over requests for reimbursements and reports submitted to LDOE. Effect: The School Board’s internal controls over cash management were weakened. Recommendations to prevent future occurrences: The School Board should establish procedures to ensure all claims for reimbursement are reviewed and approved by the required personnel in a timely manner and adequately maintained. Origination date and prior year reference (if applicable): This finding originated fiscal year ended June 30, 2024. View of responsible official: The Grants Supervisor has worked to update these procedures for the grants department. To ensure a proper review process is followed, the grants secretary will complete the reimbursement request in the system and the Grants Supervisor will review the request. If correct, the Grants Supervisor will submit the request to LDOE ensuring all request are reviewed before they are submitted. All requests will be printed and signed by the supervisor as the requests are submitted.

Reference # and title: 2023-001 Controls and Compliance over Reporting Federal program and specific federal award identification: CFDA Number Award Year FEDERAL GRANTER/ PASS THROUGH GRANTOR/PROGRAM NAME United States Department of Education; passed through Louisiana Department of Education Education Stabilization (ESSER II – Formula & Incentive) 84.425D 2021 Education Stabilization (ESSER III – Formula, Incentive & 84.425U 2021 EB Interventions) Criteria or specific requirement: In accordance with the ESSER guidelines, the School Board is required to submit an annual performance report with data on expenditures, planned expenditures, subrecipients, and uses of funds, including for mandatory reservations. The key line items include the School Board’s expenditures by ESSER subgrant, which comes from the periodic expense reports, the number of specific positions supported with ESSER funds, allocation of ESSER funds to schools and criterial used to allocate the funds to the schools and the full-time equivalent positions paid with ESSER funding. Condition found: In testing a sample of a periodic expense report from each of the School Board’s ESSER subgrants, it was noted that the ESSER III Formula subgrant did not agree with the School Board’s general ledger expenditures. In testing the information submitted through the Louisiana Department of Education’s portal for the other key line items, it was noted that the School Board could not locate their original support used to submit this information; and therefore, the auditor could not adequately test the information submitted. Context: This finding appears to be systemic. Possible asserted effect (cause effect): Cause: The School Board did not maintain all records in a secure location used to complete the report and did not reconcile the information submitted to the general ledger. Effect: The School Board did not meet all federal compliance requirements over special reporting. Recommendations to prevent future occurrences: The School Board should establish procedures to ensure all information used in completing reports to LDOE is not only maintained but also reconciles to their accounting records. Origination date and prior year reference (if applicable): This finding originated fiscal year ended June 30, 2023. View of responsible official: School Board agrees with the assessment of the auditors stated above. Due to a change in personnel, the new Grants Manager was unable to produce the documentation used by the previous Grants Manager to complete the report.

Reference # and title: 2022-002 Controls and Compliance over Davis Bacon Act Federal program and specific federal award identification: CFDA Number Award Year FEDERAL GRANTER/ PASS THROUGH GRANTOR/PROGRAM NAME United States Department of Education; passed through Louisiana Department of Education Education Stabilization (ESSER II) 84.425D 2021 Criteria or specific requirement: In accordance with the Davis Bacon Act at 29 CFR part 5, for construction contracts in excess of $2,000, the School Board is required to provide the prevailing wage rates to the potential contractors and include language in the contracts that all contractors or subcontractors must pay wages that are not less than the prevailing wage rates. Additionally, the School Board is required to perform reviews of contractors? and subcontractors? wages paid to construction workers to ensure amounts being paid are in accordance with the prevailing wage rates for the related work performed. This review includes obtaining weekly payroll reports and performing interviews of contractors? and subcontractors? employees in such frequency as necessary to assure compliance with the Davis Bacon Act. Condition found: The School Board started construction projects to install HVAC systems for two schools in the District, to install new water fountains at six schools in the District, and to install bipolar ionizers at six schools in the District and the Central Office using Education Stabilization (ESSER II) funds. The School Board did not provide the prevailing wage rates to the contractor, nor did they include the required language in the contracts. It was also noted that the School Board did not receive certified weekly payroll reports from the contractor. Context: This finding appears to be systemic. Possible asserted effect (cause effect): Cause: This is the first time the School Board received federal funds to be used for construction and therefore was not trained adequately on Davis Bacon Act procedures. Effect: The School Board did not meet all federal compliance requirements over special tests and provisions. Recommendations to prevent future occurrences: The School Board should establish procedures to ensure employees are adequately trained on Davis Bacon requirements. Origination date and prior year reference (if applicable): This finding originated fiscal year ended June 30, 2022. View of responsible official: The School Board agrees with the assessment of the auditors stated above and has taken steps to ensure employees are aware of the Davis Bacon Act requirements. Davis Bacon Act requirements have been followed on subsequent construction projects funded with Federal funds.

Reference # and title: 2019-002 Controls over Allowable Costs and Costs Principles Federal program and specific Federal award identification: This finding relates to the Child Nutrition Cluster, CFDA# 10.555 National School Lunch Program and CFDA# 10.553 School Breakfast Program, for Federal Award Year 2018, received from Federal Agency: U.S. Department of Agriculture passed through Louisiana Department of Education. Criteria or specific requirement: Good controls require expenditures to be properly approved before incurred. In accordance to the School Board?s policy over Child Nutrition Program, the approval process is over the expenditures are accounted for with the use of the purchase order. Condition found: In testing twenty disbursements, although the disbursements were for allowable costs, it was noted that six of the disbursements did not have the required purchase order in accordance with the School Board policy. Context: Twenty disbursements were selected for testing. Possible asserted effect (cause and effect): Cause: The auditor was unable to determine the cause. Effect: The controls over allowable costs were weakened. Recommendation to prevent future occurrences: The School Board should establish quality control procedures to ensure the School Board policy is followed over disbursements. Origination date and prior year reference (if applicable): This finding is first reported in the fiscal year ended June 30, 2019. View of Responsive Official: The School Board agrees with the assessment of auditors stated above.

Reference # and title: 2019-003 Procurement and Suspension and Debarment Federal program and specific Federal award identification: This finding relates to the Child Nutrition Cluster, CFDA# 10.555 National School Lunch Program and CFDA# 10.553 School Breakfast Program, for Federal Award Year 2018, received from Federal Agency: U.S. Department of Agriculture passed through Louisiana Department of Education. Criteria or specific requirement: According to 2 CFR section 200.319, the School Board is required to conduct all procurement transactions in a manner providing full and open competition for expenditures that exceed the micro-purchase and small purchase thresholds. Condition found: In testing two vendors that exceeded the micro-purchase and small purchaser thresholds, it was noted that the School Board did not having supporting documentation reflecting that one of the two selected was not conducted in a manner providing full and open competition, which was related to produce supplied to the schools. Context: Two vendors used for the Child Nutrition Program were selected for testing. Possible asserted effect (cause and effect): Cause: The School Board had performed such procedures in years before with no response for vendors. Therefore, management did not realize that these procedures should be attempted and documented each awarding year. Effect: The compliance requirements related to procurement and suspension and debarment may not have been met. Recommendation to prevent future occurrences: The School Board should establish quality control procedures to ensure the expenditure exceeding the federal thresholds where in a manner providing full and open competition and documenting such procedures. Origination date and prior year reference (if applicable): This finding is first reported in the fiscal year ended June 30, 2019. View of Responsive Official: The School Board agrees with the assessment of auditors stated above.

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